Hazardous Chemical Register: What It Must Include and How to Keep It Current
Plenty of workplaces use hazardous chemicals, even if it is only cleaning products, fuel and a few tins of paint. If they are hazardous chemicals under the WHS Regulations, you need a register. It is a simple legal document to keep, and it falls out of date quickly.
What the law requires
Under regulation 346 of the model Work Health and Safety Regulations, a PCBU must keep a register of hazardous chemicals used, handled or stored at the workplace. The register must:
- list each hazardous chemical, and
- include the current safety data sheet (SDS) for each one.
It must be kept up to date and be readily accessible to workers involved in using, handling or storing the chemicals, and to anyone else likely to be affected.
The register does not have to be a single spreadsheet. It can be a folder of current SDS with an index, or an electronic system, as long as people can get to it when they need it.
Victoria has its own rules. The OHS Regulations 2017 require a register of hazardous substances with a copy of each SDS (r 162), and the Dangerous Goods (Storage and Handling) Regulations 2022 require a dangerous goods register (r 58) and, above set quantities, a manifest (r 44).
Where SDS come from
The manufacturer or importer of a hazardous chemical must prepare an SDS (regulation 330) and review it at least every five years. As the user, your duty under regulation 344 is to obtain the current SDS from the manufacturer, importer or supplier, no later than when the chemical is first supplied to your workplace (or, if that isn’t possible, before it is used), and make it readily accessible.
Since 1 January 2023, the model WHS Regulations have used the seventh revised edition of the GHS for classifying and labelling chemicals. Safe Work Australia says SDS kept at the workplace must comply with GHS 7 from that date, even if the label is older. If any of yours were prepared under GHS 3, get a current SDS from the supplier.
Not sure what each section of an SDS is for? Our free SDS explainer lists the 16 sections an SDS must contain and who has to provide it.
Register vs manifest
These are often confused:
- Register: required for any hazardous chemical at the workplace. Lists the chemicals and holds the SDS.
- Manifest: only required when you store quantities above the manifest quantity set out in Schedule 11 (regulation 347). It records quantities, locations and storage details, and includes a site plan for emergency services. You must also notify the regulator when manifest quantities are, or will be, exceeded (regulation 348).
If you hold large quantities of fuel, gases or other dangerous goods, check the manifest thresholds as well as the register.
What to include in practice
The law only requires the list and the SDS. A few extra columns make the register far more useful:
- product name and supplier
- hazard classification
- SDS issue date and next review date
- location and typical quantity on site
- the risk assessment or controls that apply
- who is responsible for it
Keeping it current
A register goes stale in three ways: new products arrive without anyone telling safety, old products stay on the list after they are gone, and SDS pass their five-yearly review date without anyone noticing.
A few habits help:
- Gate new chemicals. No new product comes on site until the SDS is in the register and someone has looked at the risk.
- Walk the shelves. Do a physical check at least once a year and match what is there to the list.
- Track SDS dates. Flag any SDS more than five years old and request a current copy from the supplier.
- Remove what is gone. Archive old entries rather than leave them on the live list.
Chemical risks should also appear in your wider risk register. Our post on the WHS risk register in Australia covers how to link them, and our OHS and WHS legislation guide puts the chemical rules in the context of your other legal obligations. You will find more free safety resources in our WHS templates and tools.
When the spreadsheet stops working
Once you have more than one site or a few hundred products, keeping SDS dates and controls current by hand gets hard. Lahebo can hold the hazardous chemicals regulations in a legal register, linked to your risk register, with SDS checks set as actions with owners and due dates. If that would help, book a demo.
